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Case 2:12-cv-02497-KJM-EFB Document 22 Filed 10/19/12 Page 1 of 3

1 KAMALA D. HARRIS, State Bar No. 146672


Attorney General of California
2 TAMAR PACHTER, State Bar No. 146083
Supervising Deputy Attorney General
3 PAUL STEIN, State Bar No. 184956
Deputy Attorney General
4 455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
5 Telephone: (415) 703-5740
Fax: (415) 703-1234
6 E-mail: Paul.Stein@doj.ca.gov
Attorneys for California State Defendants
7

8 IN THE UNITED STATES DISTRICT COURT


9 FOR THE EASTERN DISTRICT OF CALIFORNIA
10 SACRAMENTO DIVISION
11

12
PICKUP, ET AL., 2:12-cv-02497
13
Plaintiff, STIPULATION AND [PROPOSED]
14 ORDER RE: (1) BRIEFING AND
v. HEARING SCHEDULE ON
15 PLAINTIFFS’ MOTION FOR A
PRELIMINARY INJUNCTION; (2)
16 BROWN, ET AL., PAGE LIMITS FOR BRIEFING ON
PLAINTIFFS’ MOTION; AND (3)
17 Defendant. CALIFORNIA STATE DEFENDANTS’
TIME TO ANSWER OR OTHERWISE
18 RESPOND TO PLAINTIFFS’
COMPLAINT
19
Date:
20 Time:
Courtroom: 3, 15th Floor
21 Judge: The Honorable Kimberly J.
Mueller
22 Trial Date: None set
Action Filed: October 4, 2012
23

24 Plaintiffs David Pickup et al. (Plaintiffs) and Defendants Edmund G. Brown, Jr., Governor
25 of the State of California in his official capacity; Anna M. Caballero, Secretary of the California
26 State and Consumer Services Agency, in her official capacity; Kim Madsen, Executive Officer of
the California Board of Behavioral Sciences, in her official capacity; Michael Erickson, President
27
of the California Board of Psychology, in his official capacity; and Sharon Levine, President of
28
1
Stipulation re Plaintiffs’ MPI; Page Limits; Defendants’ Time To Respond (2:12-cv-02497)
Case 2:12-cv-02497-KJM-EFB Document 22 Filed 10/19/12 Page 2 of 3

1 the Medical Board of California, in his official capacity (collectively, the California State
2 Defendants), by and through their respective counsel, hereby stipulate and agree as follows:

3 (1) On October 15, 2012, Plaintiffs served the summons and complaint in this action,
as well as separate motions for a preliminary injunction and to proceed using pseudonyms, on the
4
California State Defendants;
5
(2) Plaintiffs noticed hearings on their motions for November 9, 2012, less than
6 twenty-eight (28) days from the date of service, and submitted a brief in excess of twenty (20)
7 pages in support of their motion for a preliminary injunction; Plaintiffs subsequently filed a
8 motion seeking leave to exceed the page limit, which motion has not been decided; and

9 (3) On October 18, 2012, the parties met and conferred and reached agreement
regarding the briefing and hearing schedule on Plaintiffs’ motions for a preliminary injunction
10
and to proceed using pseudonyms; Plaintiffs’ overlong brief in support of its motion for a
11
preliminary injunction; and the California State Defendants’ deadline to answer or otherwise
12
respond to the complaint in this action, which is presently November 5, 2012.
13 Now, based on the foregoing, and in the interests of conserving party and judicial
14 resources, and the orderly and efficient administration of this case, the parties further stipulate
15 and agree that:
(A) The hearing on Plaintiffs’ motions for a preliminary injunction and to proceed
16
using pseudonyms shall be held on Friday, November 30, 2012, at 10:00 a.m. in the above-
17
referenced courtroom;
18
(B) Plaintiffs’ overlong memorandum of points and authorities in support of their
19 motion for a preliminary injunction, filed on October 4, 2012, and Plaintiffs’ motion for leave to
20 file an overlong brief, filed on October 11, 2012, are hereby withdrawn;
21 (C) Plaintiffs shall re-file and serve their memorandum of points and authorities in

22 support of their motion for a preliminary injunction, which shall not exceed thirty (30) pages, no
later than Monday, October 22, 2012;
23
(D) The California State Defendants shall file and serve their opposition to the motion
24
for a preliminary injunction, which shall not exceed thirty (30) pages, and their opposition, if any,
25 to Plaintiffs’ motion to proceed using pseudonyms, no later than Friday, November 9, 2012;
26 (E) Plaintiffs shall file and serve their reply in support of their motion for a
27 preliminary injunction, if any, which shall not exceed fifteen (15) pages, no later than Friday,

28 November, 16, 2012; and


2
Stipulation re Plaintiffs’ MPI; Page Limits; Defendants’ Time To Respond (2:12-cv-02497)
Case 2:12-cv-02497-KJM-EFB Document 22 Filed 10/19/12 Page 3 of 3

1 (F) The California State Defendants shall answer or otherwise respond to the
2 complaint in this action no later than twenty-one (21) days after this Court issues its ruling on

3 Plaintiffs’ motion for a preliminary injunction.

4
Dated: October 19, 2012 Respectfully submitted,
5
KAMALA D. HARRIS
6 Attorney General of California
TAMAR PACHTER
7 Supervising Deputy Attorney General
8

9 /s/ Paul Stein


PAUL STEIN
10 Deputy Attorney General
Attorneys for California State Defendants
11

12 LIBERTY COUNSEL
P.O. BOX 11108
13 Lynchburg, VA 24506
Tel: (434) 592-7000
14 Fax: (434) 592-7700
Email: court@lc.org
15

16 /s/ Mary E. McAlister


MARY E. MCALISTER (SBN148570)
17 Attorneys for Plaintiffs David Pickup et al.
18
SA2012108115
19 20645070.doc
20

21
HAVING CONSIDERED THE STIPULATION OF THE PARTIES, AND GOOD CAUSE
22
APPEARING, IT IS SO ORDERED:
23

24
Dated: _____________________ ___________________________
25
Hon. Kimberly J. Mueller
26

27

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3
Stipulation re Plaintiffs’ MPI; Page Limits; Defendants’ Time To Respond (2:12-cv-02497)